Table 1: Annual Respondent Burden and Cost – NESHAP for Stationary Reciprocating Internal Combustion Engines (40 CFR Part 63, Subpart ZZZZ) (Renewal) |
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2019 Labor Rates |
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Burden Item |
A |
B |
C |
D |
E |
F |
G |
H |
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Technical |
$120.27 |
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Technical person-hours per occurrence |
No. of occurrences per respondent per year |
Technical person-hours per respondent per year (AxB) |
Respondents per year a |
Technical hours per year (CxD) |
Management hours per year (Ex0.05) |
Clerical hours per year (Ex0.10) |
Total cost per year b ($) |
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Management |
$141.06 |
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1. Applications |
N/A |
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Clerical |
$58.67 |
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2. Surveys and Studies |
N/A |
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3. Reporting Requirements |
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A. Familiarize with rule requirement |
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New sources |
4 |
1 |
4 |
1,284 |
5,136 |
257 |
514 |
$684,063.84 |
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Affected Sources Estimates |
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Existing sources |
1 |
1 |
1 |
153,463 |
153,463 |
7,673 |
15,346 |
$20,439,736.97 |
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B. Required Activities c |
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1975.04 |
New Sources, Non-Exempt (see ICR, p. 1) |
769 |
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Device |
ERG, EV:
Basis: see ICR 1975.04 (p. 9)
No. Sources |
Capital/Startup |
O&M |
|
4-SRB >5,000 HP (once per year) |
24 |
1 |
24 |
86 |
2,064 |
103 |
206 |
$274,904.16 |
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New Sources, Exempt (see ICR, p. 1) |
105 |
|
CO monitor |
682 |
$583 |
-- |
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4-SRB ≥5,000 HP (once per year) |
8 |
1 |
8 |
1 |
8 |
0.4 |
0.8 |
$1,065.52 |
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CO monitor |
3,054 |
-- |
$1,873 |
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Quarterly Performance Test (Facilities with Multiple RICE) |
24 |
4 |
96 |
1,605 |
154,080 |
7,704 |
15,408 |
$20,521,915.20 |
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Press. & Temp. (Small) |
769 |
$1,708 |
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Quarterly Performance Test (Facilities with One RICE) |
6 |
1 |
6 |
5 |
30 |
1.5 |
3 |
$3,995.70 |
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Press. & Temp. (Large) |
366 |
$421 |
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Semiannual Performance Test |
24 |
2 |
48 |
4,869 |
233,712 |
11,686 |
23,371 |
$31,128,101.28 |
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Existing Sources (see ICR, p. 10) |
ERG, EV:
Basis: sum of new sources from 2005 to 2013 plus existing sources from 2005.
11,096 |
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C. Gather Existing Information |
Included in 3D |
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1975.05 |
New Sources, Area (see ICR, p. 21) |
ERG, EV:
Basis: 350 new sources in 2008, 360 new sources in 2009, 370 new sources in 2010, etc., until ICR midpoint (i.e., 2014) (see ICR, p. 21).
410 |
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Device |
No. Sources |
Capital/Startup |
O&M |
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D. Write Report |
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Portable CO Monitor |
410 |
$583 |
$1,873 |
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Notification of Construction/Reconstruction d |
2 |
1 |
2 |
1,179 |
2,358 |
118 |
236 |
$314,062.02 |
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Press. & Temp. Monitor |
410 |
$1,708 |
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Notification of Anticipated Startup d |
2 |
1 |
2 |
1,179 |
2,358 |
118 |
236 |
$314,062.02 |
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Existing Sources (see ICR, p. 21) |
ERG, EV:
Basis: sum of new sources from 2008 to 2013 (see ICR, p. 21).
2,250 |
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Notification of Actual Startup d |
2 |
1 |
2 |
1,179 |
2,358 |
118 |
236 |
$314,062.02 |
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1975.07 |
New Sources |
0 |
Covers CI RICE |
No capital/startup or O&M costs. |
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Notification of Performance Test c |
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Existing Sources (see ICR, p. 23) |
825,545 |
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Quarterly |
2 |
4 |
8 |
1,605 |
12,840 |
642 |
1,284 |
$1,710,159.60 |
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"Semiannual Reporters" |
60,654 |
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Semiannually |
2 |
2 |
4 |
4,460 |
17,840 |
892 |
1,784 |
$2,376,109.60 |
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"Annual Reporters" |
25,995 |
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Anually |
2 |
1 |
2 |
87 |
174 |
8.7 |
17 |
$23,175.06 |
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"Monitoring" |
19,678 |
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Initial Notification for Exempt RICE |
2 |
1 |
2 |
105 |
210 |
10.5 |
21 |
$27,969.90 |
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"Recordkeeping" |
738,896 |
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Initial Notification of Compliance d |
2 |
1 |
2 |
1,179 |
2,358 |
118 |
236 |
$314,062.02 |
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1975.08 |
New Sources |
0 |
Covers SI RICE |
No capital/startup or O&M costs. |
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Semiannual Compliance Report e |
1 |
2 |
2 |
127,022 |
254,044 |
12,702 |
25,404 |
$33,836,120.36 |
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Existing Sources (see ICR, p. 22) |
62,167 |
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Annual Compliance Report f |
1 |
1 |
1 |
25,995 |
25,995 |
1,300 |
2,600 |
$3,462,274.05 |
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"Reporting" |
45,633 |
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Annual Compliance Report (Emergency RICE) g |
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"Monitoring" |
15,299 |
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Utilities |
16 |
0.33 |
5.33 |
446 |
2,379 |
119 |
238 |
$316,814.61 |
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"Recordkeeping" |
16,534 |
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Curtailment Service Providers |
1,000 |
0.33 |
333.33 |
70 |
23,333 |
1,167 |
2,333 |
$3,107,766.67 |
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1975.09 |
New Sources |
0 |
Covers Emergency RICE |
No capital/startup or O&M costs. |
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Reporting Subtotal |
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1,028,951 |
$119,170,421 |
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ERG, EV:
Link:
www.federalregister.gov/articles/2013/01/30/2013-01288/national-emission-standards-for-hazardous-air-pollutants-for-reciprocating-internal-combustion#h-14
Existing Sources (see 78 FR 6674) |
446 |
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4. Recordkeeping Requirements |
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Utilities |
446 |
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A. Familiarize with rule requirement |
Included in 3A |
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Curtailment Service Providers |
70 |
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B. Train Personnel d |
16 |
1 |
16 |
1,179 |
18,864 |
943 |
1,886 |
$2,512,496.16 |
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1975.10 |
New Sources |
1,284 |
Covers all sources |
Device |
No. Sources |
Capital/Startup |
O&M |
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C. Continuous Monitoring h |
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Major - non-exempt |
769 |
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CO monitor |
1,179 |
$687,357 |
$32,211,854 |
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Portable CO Monitor |
40 |
1 |
40 |
410 |
16,400 |
820 |
1,640 |
$2,184,316.00 |
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Major - exempt |
105 |
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CPMS - small |
1,179 |
$2,013,732 |
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Pressure and Temperature |
30 |
1 |
30 |
48,323 |
1,449,690 |
72,485 |
144,969 |
$193,084,211.10 |
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Area |
410 |
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CPMS - large |
366 |
$156,282 |
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D. Record Information |
1 |
1 |
1 |
768,776 |
768,776 |
38,439 |
76,878 |
$102,393,275.44 |
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TOTAL |
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$2,857,371 |
$32,211,854 |
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Recordkeeping Subtotal |
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2,591,790 |
$300,174,299 |
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Sources with initial notification requirements (non-exempt only) |
1,179 |
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TOTAL LABOR BURDEN AND COSTS (rounded) i |
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3,620,000 |
$419,000,000 |
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Existing Sources |
149,926 |
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TOTAL CAPITAL AND O&M COST (rounded) i |
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$41,700,000 |
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Major |
13,718 |
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GRAND TOTAL (rounded) i |
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$461,000,000 |
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Area |
3,480 |
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CI engines |
86,649 |
*only 60,654 submit semiannual reports |
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Assumptions: |
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SI engines |
45,633 |
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a We estimate an average of 153,463 existing respondents and 1,284 new respondents will be subject to the standard per year over the three-year period of this ICR. The number of existing respondents include 16,025 major source stationary RICE (>500 hp), 4,710 area source stationary RICE, 86,649 CI engines, 45,633 SI engines, and 446 utilities. The number of new respondents includes 769 non-exempt major stationary RICE (>500 hp), 105 exempt major stationary RICE (>500 hp), and 410 area sources. |
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Utilities |
446 |
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b This ICR uses the following labor rates: $141.06 per hour for Executive, Administrative, and Managerial labor; $120.27 per hour for Technical labor, and $58.67 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. |
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c The estimated number of sources for these activities was obtained from EPA ICR Number 1975.04. |
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Sources that submit semiannual reports |
123,485 |
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d We assume all non-exempt new sources have to complete these activities (1,284 new sources - 105 major exempt new sources = 1,179 sources). |
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Existing sources that only keep records |
755,430 |
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e We assume 127,022 existing sources have to write semiannual reports. This estimate includes 16,025 existing major source stationary RICE (>500 hp), 4,710 existing area sources, 60,654 existing CI engines, and 45,633 existing SI engines. |
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1975.11 |
New Sources |
1,284 |
*New respondents include 769 major source non-exempt stationary RICE (>500 hp), 105 major source exempt stationary RICE (>500 hp), and 410 area source stationary RICE. |
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f We assume 25,995 existing CI engines have to complete annual reports. This estimate is based on EPA ICR Number 1975.07. |
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Major - non-exempt |
769 |
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g We assume 446 local utilities and 16 hours per annual report, and 70 curtailment service providers with 1,000 hours per report. This estimate is based on the January 2013 Final Rule amendment. Reporting requirements for emergencies RICE will begin in 2016 which is the final year covered in this ICR. Therefore, we assume an average annual occurrence of 0.33 (once every three years) for this ICR. |
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Major - exempt |
105 |
*includes new sources which are exempt but have an initial notification requirement (105 per year or 315 over 3 years). |
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h These estimates were obtained from EPA ICR Number 1975.04, 1975.05, 1975.07 and 1975.08. |
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Area |
410 |
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i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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Sources with initial notification requirements (non-exempt only) |
1,179 |
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Existing Sources |
153,463 |
Existing respondents include 16,025 major source stationary RICE (>500 hp), 4,710 area source stationary RICE, 86,649 CI engines, 45,633 SI engines, and 446 utilities. |
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4-SRB - 4-Stroke Rich Burn |
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Major |
16,025 |
*Adds existing (cellN43) to new major (non-exempt) (cellN37)*3 years |
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Area |
4,710 |
*Adds existing (cellN44) to new area (cellN39)*3 years |
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CI engines |
86,649 |
*pulled from 1975.10 - note only 60,654 submit semiannual reports, remaing 25,995 submit annual reports |
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SI engines |
45,633 |
*pulled from 1975.10 |
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Utilities |
446 |
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Sources that submit semiannual reports |
127,022 |
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Existing sources that only keep records |
755,430 |
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3.4 |
hr/response |
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Table 2: Average Annual EPA Burden and Cost – NESHAP for Stationary Reciprocating Internal Combustion Engines (40 CFR Part 63, Subpart ZZZZ) (Renewal) |
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Labor Rates |
Burden Item |
A |
B |
C |
D |
E |
F |
G |
H |
|
Technical |
$49.44 |
Technical person-hours per occurrence |
No. of occurrences per respondent per year |
Technical person-hours per respondent per year (AxB) |
Respondents per year a |
Technical hours per year (CxD) |
Management hours per year (Ex0.05) |
Clerical hours per year (Ex0.10) |
Total cost per year ($) b |
|
Management |
$66.62 |
Report review |
|
|
|
|
|
|
|
|
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Clerical |
$26.75 |
Notification of Construction/Reconstruction |
1 |
1 |
1 |
1,179 |
1,179 |
59 |
118 |
$65,370.83 |
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Notification of Anticipated Startup |
1 |
1 |
1 |
1,179 |
1,179 |
59 |
118 |
$65,370.83 |
|
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|
Notification of Actual Startup |
1 |
1 |
1 |
1,179 |
1,179 |
59 |
118 |
$65,370.83 |
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Notification of Performance Test |
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Quarterly |
1 |
4 |
4 |
1,605 |
6,420 |
321 |
642 |
$355,963.32 |
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Semiannually |
1 |
2 |
2 |
4,460 |
8,920 |
446 |
892 |
$494,578.32 |
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Annually |
1 |
1 |
1 |
87 |
87 |
4 |
9 |
$4,823.80 |
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Initial Notification for Exempt RICE |
1 |
1 |
1 |
105 |
105 |
5 |
11 |
$5,821.83 |
|
|
|
Initial Notification of Compliance |
2 |
1 |
2 |
1,179 |
2,358 |
118 |
236 |
$130,741.67 |
|
|
|
Semiannual Compliance Report c |
2 |
2 |
4 |
127,022 |
508,088 |
25,404 |
50,809 |
$28,171,447.25 |
|
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Annual Compliance Report d |
2 |
2 |
4 |
26,511 |
106,044 |
5,302 |
10,604 |
$5,879,715.62 |
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TOTAL (rounded) e |
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|
|
731,000 |
$35,200,000 |
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|
|
|
|
|
|
|
|
|
Assumptions: |
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|
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|
|
a We estimate an average of 153,463 existing respondents and 1,284 new respondents will be subject to the standard per year over the three-year period of this ICR. The number of existing respondents include 16,025 major source stationary RICE (>500 hp), 4,710 area source stationary RICE, 86,649 CI engines, 45,633 SI engines, and 446 utilities. The number of new respondents includes 769 non-exempt major stationary RICE (>500 hp), 105 exempt major stationary RICE (>500 hp), and 410 area sources. |
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b This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. |
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c We assume 127,022 existing sources have to write semiannual reports. This estimate includes 16,025 existing major source stationary RICE (>500 hp), 4,710 existing area sources, 60,654 existing CI engines, and 45,633 existing SI engines. |
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d We assume 25,995 existing CI engines, 446 local utilities, and 70 curtailment service providers have to complete annual reports. This estimate is based on EPA ICR Number 1975.07 and the January 2013 Final Rule amendment. |
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e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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Number of Respondents |
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Capital/Startup vs. Operation and Maintenance (O&M) Costs |
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Respondents That Submit Reports |
Respondents That Do Not Submit Any Reports |
|
Total Annual Responses |
|
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
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Year |
(A) Number of New Respondentsa |
(B) Number of Existing Respondentsb |
(C) Number of Existing Respondents that keep records but do not submit reportsc |
(D) Number of Existing Respondents That Are Also New Respondents |
(E) Number of Respondents (E=A+B+C-D) |
|
(A) Information Collection Activity |
(B) Average Number of Respondents |
(C) Number of Responses |
(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports |
(E) Total Annual Responses E=(BxC)+D |
|
Continuous Monitoring Device |
Capital/Startup Cost for One Respondent |
Number of New Respondents a |
Total Capital/Startup Cost, (B X C) |
Annual O&M Costs for One Respondent |
Number of Respondents with O&M b |
Total O&M, (E X F) |
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|
|
1 |
1,284 |
152,179 |
755,430 |
0 |
908,893 |
|
Notification of construction/reconstruction |
1,179 |
1 |
0 |
1,179 |
|
CO monitors c |
$583 |
1,179 |
$687,357 |
$1,873 |
20,735 |
$38,836,655 |
|
|
|
2 |
1,284 |
153,463 |
755,430 |
0 |
910,177 |
|
Notification of anticipated startup |
1,179 |
1 |
0 |
1,179 |
|
CPMS - small d |
$1,708 |
1,179 |
$2,013,732 |
N/A |
N/A |
|
|
|
|
3 |
1,284 |
154,747 |
755,430 |
0 |
911,461 |
|
Notification of actual startup |
1,179 |
1 |
0 |
1,179 |
|
CPMS - large d, e |
$427 |
366 |
$156,282 |
N/A |
N/A |
|
|
|
|
Average |
1,284 |
153,463 |
755,430 |
0 |
910,177 |
|
Notification of performance test |
|
|
|
|
|
Total f |
|
|
$2,860,000 |
|
|
$38,800,000 |
|
$41,700,000 |
|
|
|
|
|
|
|
|
Quarterly |
1,605 |
4 |
0 |
6,420 |
|
|
|
|
|
|
|
|
|
|
|
a New respondents include 769 major source non-exempt stationary RICE (>500 hp), 105 major source exempt stationary RICE (>500 hp), and 410 area source stationary RICE (1,284 respondents total). The 105 major source exempt stationary RICE submit an initial notification but do not submit reports. |
|
Semiannually |
4,460 |
2 |
0 |
8,920 |
|
a We estimate there 769 (non-exempt) new major source stationary RICE greater than 500 hp and 410 new area source stationary RICE per year. We assume all non-exempt new sources will incur capital costs. (769 + 410 = 1,179 sources) There are an additional 105 exempt new major stationary RICE sources. |
|
b Existing respondents include 16,025 major source stationary RICE (>500 hp), 4,710 area source stationary RICE, 86,649 CI engines, 45,633 SI engines, and 446 utilities (153,463 respondents total). |
|
Annually |
87 |
1 |
0 |
87 |
|
b We estimate an average of 16,025 existing major source stationary RICE greater than 500 hp and 4,710 existing area source stationary RICE per year will have O&M costs over the three-year period of this ICR. (16,025 + 4,710 = 20,735 sources) |
|
c Existing respondents that do not submit reports include 738,896 CI engines and 16,534 SI engines (738,896 + 16,534 = 755,430). |
|
Initial notification for exempt RICE |
105 |
1 |
0 |
105 |
|
c Each facility can purchase one portable CO monitor and use it for several stationary RICE. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Initial notification of compliance |
1,179 |
1 |
0 |
1,179 |
|
d CPMS – continuous parameter monitoring system for temperature monitoring and monthly pressure drop measurement. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Semiannual compliance report |
127,022 |
2 |
755,430 |
1,009,474 |
|
e We assume that only 366 of the 769 new (non-exempt) major source stationary RICE (>500 hp) have to additionally purchase large CPMS. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Annual compliance report |
26,511 |
1 |
0 |
26,511 |
|
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total |
1,056,233 |
|
|
|
|
|
|
|
|
|
|